ID: aiam0352

Dear Mr. Leventhal: This is in reply to your letter of May 14, 1971, on the subject of th effective date of the requirements for seat belts and seat belt anchorages in multipurpose passenger vehicles.; You have been correctly informed by RVI that the seat belt installatio standard (No. 208), and the seat belt anchorage standard (No. 210) are effective July 1, 1971, with respect to trucks and multipurpose passenger vehicles. The amendment to Standard No. 208 issued September 30, 1970, required seat belts effective July 1, 1971. That standard will be superseded by the new occupant crash protection standard on January 1, 1972, but it is in full effect from July 1, 1971, to January 1, 1972. We regret any confusion that may have arisen as the result of the issuance of the occupant crash protection standard.; The requirements for seat belt anchorages have not been affected in an way by the occupant crash protection rule and it is therefore surprising to find that the effective date of the anchorage standard has also been misunderstood. We would hope that the changes in procurement schedule to which you refer would not result in inability to conform to the standard by July 1, 1971.; On the basis of the information presently available to us there doe not appear to be sufficient cause to postpone the effective dates of Standards No. 208 and 210.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel

ID: 14896-4.pja

Mr. Charles Jandecka
4481 Dover Center Road
North Olmsted, Ohio 44070

Dear Mr. Jandecka:

I apologize for the delay in responding to your letter requesting a reevaluation of Federal Motor Vehicle Safety Standard No. 205, Glazing Materials (49 CFR 571.205), as it relates to tinting of windows. Specifically, you expressed concern about the increase in the number of vehicles with dark-tinted windows.

As you know, Standard No. 205 requires vehicle windows that are "requisite for driving visibility" to meet a 70 percent light transmittance requirement. Darker windows are currently allowed in the rear and rear side windows on trucks, buses, and multi-purpose vehicles (MPVs) because the agency has issued an interpretation stating that these windows are not requisite for driving visibility.

You would like the National Highway Traffic Safety Administration (NHTSA) to prohibit dark-tinted windows in light trucks, MPVs, and vans. You disagree with the conclusion of the agency's interpretation that these windows are not requisite for driving visibility. In addition, you argue that sport utility vehicles and vans should not be relieved of the light transmittance requirement by the interpretation because they do not meet the definition of an MPV. An MPV is ". . . constructed either on a truck chassis or with special features for occasional off-road operation." 49 CFR 571.3.

I will first address your argument regarding classification of vehicles. In contending that these vehicles are not MPVs, you argued that sport utility vehicles were not "off-road vehicles," which you found defined in Executive Order No. 11644 and 16 USC 670. We note that these authorities are not relevant to our regulations. But more importantly, this argument fails to recognize the distinction between a "vehicle with features for occasional off-road operation," and a more capable "off-road vehicle." The definition for off-road vehicles, such as the Humvee, is not relevant to whether vans and sport utility vehicles are MPVs.

Sport utility vehicles clearly meet the MPV definition. They have "special features for occasional off-road operation" such as four-wheel drive, large all purpose tires, large suspension excursions, and high ground clearances. The fact that they offer interior amenities and are often not driven off-road by their owners does not nullify these special features. The classifications are based on design, because ultimate use is something the manufacturer generally does not know. The presence of some of these features on vehicles certified as passenger cars also does not nullify their presence on sport utility vehicles.

Some vans and minivans meet the definition of trucks. Most cargo vans are classified as "trucks" under our safety standards. A truck is defined in 49 CFR 571.3 as being ". . . designed primarily for the transportation of property or special purpose equipment." Many full-size vans are designed on a chassis that may be fitted with any number of body types and is designed and used primarily for carrying cargo.

Most passenger vans and minivans are classified as "multipurpose passenger vehicles," because they are considered by their manufacturers to be "constructed on a truck chassis." Some manufacturers may classify them as MPVs because of heavier running gear, front suspensions, and rear leaf springs, for greater load-carrying capacity. In addition, the rear seats are often removable for carrying large cargo rather than passengers, supporting a colloquial definition of "multi-purpose" vehicles.

Generally speaking, designation of the vehicle type is up to the manufacturer. The definitions of trucks and MPVs overlap somewhat. NHTSA's main concern is that all vehicles meet the standards applicable to the type of vehicle as which they are certified. The agency is aware that in recent years changes in the construction of minivans and sport utility vehicles have tended to blur the line between these vehicles and passenger cars. There has been a convergence in the safety standards applicable to these vehicles and the standards applicable to passenger cars. NHTSA has not tried to create a complex distinction between these vehicle types, but has instead allowed the industry to produce innovative designs that meet the demands of the marketplace.

Moreover, the manufacturers have for many years continued classifying vans and minivans as light trucks for the purpose of complying with the Corporate Average Fuel Economy (CAFE) requirements. The vehicle classification requirements in 49 CFR 523.5(a)(5) allow manufacturers to properly classify vans and minivans with removable seats as light trucks for that purpose. It is doubtful the industry could comply with the CAFE standards if NHTSA suddenly restricted classification capabilities. Therefore, given the industry's longstanding reliance on NHTSA's interpretation and regulation in this area, this office cannot make a such a drastic change in the context of an interpretation letter.

Turning now to your question of whether the rear and rear side windows of sport utility vehicles and vans should be considered "requisite for driving visibility," we continue to believe that they should not be. You correctly identified a change in the agency's opinion between the July 16, 1973 interpretation of Richard Dyson and the April 4, 1985 interpretation of Jeffrey Miller, which first announced the conclusion that these windows were not requisite for driving visibility. However, you are incorrect to conclude that either the January 9, 1990 interpretation by Stephen Wood, or any of the subsequent interpretations you cited represent a change in the agency's position on the matter. Mr. Miller's interpretation still represents the agency's position.

The reasoning behind the Miller interpretation is that these vehicles are often sold in configurations without windows or with small windows to the rear of the driver (e.g., a panel van). Even if the windows to the rear of the driver are large enough, these vehicles may frequently carry loads that block the view out of them. Logically, it is impossible to argue that these windows are requisite for driving visibility when they do not even exist on the next van on the lot. In addition, most minivans and sport utility vehicles today, (even those with larger side windows and without a vision-blocking load) have rear side windows that are too high to rely on for lane changes. Vehicle manufacturers provide right-side rear view mirrors on these vehicles which assist in lane changes.

If these windows were requisite for driving visibility, one might expect that vehicle types with darker glass in those locations would be more involved in crashes, but the data do not show this to be true. Some analyses have shown that they are generally less involved in crashes than passenger cars, and that they are even under-involved in lane change crashes. This indicates that the existing window and mirror systems are meeting the minimum needs for driving visibility.

On January 22, 1992, NHTSA proposed, among other things, transmittance requirements for the windows to the rear of the driver in these vehicles. The proposed requirements would permit windows darker than those in passenger cars, but would require these windows to be lighter than the "privacy glass" currently being sold on some minivans and sport utility vehicles. Comments on the proposal were overwhelmingly negative. The law enforcement community was divided on the issue. Final action on this rulemaking is anticipated soon.

I hope this information is helpful. If you have any further questions, please feel free to contact Paul Atelsek of my staff at this address or by telephone at (202) 366-2992.

Sincerely,
John Womack
Acting Chief Counsel
ref:205
d.3/10/98

ID: aiam2541

Dear Mr. Bynum: This responds to your February 18, 1977, letter asking whether Standar No. 222, *School Bus Passenger Seating and Crash Protection*, permits the use of a two-passenger front-row seat with a corresponding two-passenger front-row restraining barrier. Secondly, you ask whether the State of Virginia can require the use in joints of discrete fasteners and welding, and not adhesives, without conflicting with the requirements of Standard No. 221, *School Bus Body Joint Strength*. Finally, you ask who must certify that a vehicle complies with Standard No. 105, *Hydraulic Brake Systems*.; The NHTSA has issued an interpretation allowing the use of a two passenger front-row seat with a two-passenger restraining barrier. This can be accomplished by the use of a two-passenger seat cushion and a three-passenger seat back as you suggest. I am enclosing a copy of the NHTSA interpretation for your information.; Regarding your second question concerning the use of adhesives in bu body joints, the Federal bus body joint standard requires only that joints meet a specified strength requirement. The NHTSA does not require any particular type of joint construction. Therefore, the purchaser and manufacturer can decide upon any method of joint construction as long as the joint meets Federal strength specifications.; Your final question asks who must certify that a small school bu (under 10,000 pounds) is in compliance with Standard No. 105, *Hydraulic Brake Systems*. To assign responsibility for the certification of multi-stage vehicles, NHTSA has issued Part 568, *Vehicles Manufactured in Two or More Stages* (enclosed). The manufacturer of an 'incomplete-vehicle' (such as a cab-chassis) must provide documentation to the intermediate- and final-stage manufacturer of the vehicle on how to complete it so that it complies with all applicable standards. It is the responsibility of the final- stage manufacturer to affix a certification label unless the incomplete- or intermediate-stage manufacturer assumes this responsibility.; On a related matter concerning small school buses, it is ou understanding that school buses weighing under 10,000 pounds will be available after April 1, 1977.; Sincerely, Frank A. Berndt, Acting Chief Counsel

ID: aiam2538

Dear Mr. Bynum: This responds to your February 18, 1977, letter asking whether Standar No. 222, *School Bus Passenger Seating and Crash Protection*, permits the use of a two-passenger front-row seat with a corresponding two-passenger front-row restraining barrier. Secondly, you ask whether the State of Virginia can require the use in joints of discrete fasteners and welding, and not adhesives, without conflicting with the requirements of Standard No. 221, *School Bus Joint Strength*. Finally, you ask who must certify that a vehicle complies with Standard no. 105, *Hydraulic Brake Systems*.; The NHTSA has issued an interpretation allowing the use of two-passenger front-row seat with a two-passenger restraining barrier. This can be accomplished by the use of a two-passenger seat cushion and a three-passenger seat back as you suggest. I am enclosing a copy of the NHTSA interpretation for your information.; Regarding your second question concerning the use of adhesives in a bu body joints, the Federal bus body joint standard requires only that joints meet a specified strength requirement. The NHTSA does not require any particular type of joint construction. Therefore, the purchaser and manufacturer can decide upon any method of joint construction as long as the joint meets Federal strength specifications.; Your final question asks who must certify that a small school bu (under 10, 000 pounds_ is in compliance with Standard No.105, *Hydraulic Brake System*. To assign responsibility for the certification of multi-stage vehicles, NHTSA has issued Part 568, *Vehicles Manufactured in Two or More Stages* (enclosed). The manufacturer of an 'incomple- te-vehicle' (such as a cab-chassis) must provide documentation to the intermediate- and final-stage manufacturer of the vehicle on how to complete it so that it complies with all applicable standards. it is the responsibility of the final-stage manufacturer to affix a certification label unless the incomplete- or intermediate-stage manufacturer assumes this responsibility.; On a related matter concerning small school buses, it is ou understanding that school buses weighing under 10, 000 pounds will be available after April 1, 1977.; Sincerely, Frank A. Berndt, Acting Chief Counsel

ID: aiam2543

Dear Mr. Bynum: This responds to your February 18, 1977, letter asking whether Standar No. 222, *School Bus Passenger Seating and Crash Protection*, permits the use of a two-passenger front-row seat with a corresponding two-passenger front-row restraining barrier. Secondly, you ask whether the State of Virginia can require the use in joints of discrete fasteners and welding, and not adhesives, without conflicting with the requirements of Standard No. 221, *School Bus Body Joint Strength*. Finally, you ask who must certify that a vehicle complies with Standard No. 105, *Hydraulic Brake Systems*.; The NHTSA has issued an interpretation allowing the use of a two passenger front-row seat with a two-passenger restraining barrier. This can be accomplished by the use of a two-passenger seat cushion and a three-passenger seat back as you suggest. I am enclosing a copy of the NHTSA interpretation for your information.; Regarding your second question concerning the use of adhesives in bu body joints, the Federal bus body joint standard requires only that joints meet a specified strength requirement. The NHTSA does not require any particular type of joint construction. Therefore, the purchaser and manufacturer can decide upon any method of joint construction as long as the joint meets Federal strength specifications.; Your final question asks who must certify that a small school bu (under 10,000 pounds) is in compliance with Standard No. 105, *Hydraulic Brake Systems*. To assign responsibility for the certification of multi-stage vehicles, NHTSA has issued Part 568, *Vehicles Manufactured in Two or More Stages* (enclosed). The manufacturer of an 'incomplete-vehicle' (such as a cab-chassis) must provide documentation to the intermediate- and final-stage manufacturer of the vehicle on how to complete it so that it complies with all applicable standards. It is the responsibility of the final- stage manufacturer to affix a certification label unless the incomplete- or intermediate-stage manufacturer assumes this responsibility.; On a related matter concerning small school buses, it is ou understanding that school buses weighing under 10,000 pounds will be available after April 1, 1977.; Sincerely, Frank A. Berndt, Acting Chief Counsel

ID: aiam4109

Dear Mr. Spencer: This responds to your March 11, 1986 letter to this office askin several questions about the applicability of our school bus regulations to vans. In a March 5 telephone conversation with Ms. Hom of my staff, you explained your concern with Florida's position against use of conventional vans on school-related activities. While you were aware that it would be more appropriate to discuss your suggestions for changing Florida's laws with state officials, you requested us to clarify our regulations for school buses. Your letter included several specific questions about our school bus requirements.; From the correspondence enclosed with your letter, we understand tha Florida's concern over school bus safety resulted in a prohibition against school boards' condoning the transportation of students to school related events in vans that do not meet Federal or State school bus safety standards. This prohibition applies to school-owned vehicles as well as to vehicles owned by parents wishing to transport their children to extracurricular activities. Florida does not prevent parents from transporting children in their vans if the transportation is not sponsored or required by the school board and if parents assume responsibility for carrying school children.; Before I respond to your specific questions, some background discussio on our school bus regulations would be helpful. The National Traffic and Motor Vehicle Safety Act authorizes NHTSA to regulate the manufacture and sale of all new motor vehicles, including school buses. Under the Vehicle Safety Act we issued comprehensive motor vehicle safety standards for various aspects of school bus safety, including emergency exits, seating systems, windows and windshields, and fuel systems. Under Federal law, a 'school bus' is defined as a bus (i.e., a motor vehicle designed to carry 11 or more persons, driver included) sold for purposes that include carrying students to or from school or related events (common carriers in urban transportation excluded). Federal law requires all manufacturers to certify that each new school bus complies with our school bus safety standards and requires persons selling new school buses to ensure that only certified vehicles are sold. Any person who fails to comply with the requirements of the Vehicle Safety Act is subject to civil penalties under the Act.; In addition, NHTSA has a separate set of recommendations for stat pupil transportation programs which was issued under the Highway Safety Act. Those recommendations are found in Highway Safety Program Standard No. 17, *Pupil Transportation Safety* (copy enclosed), and include guidelines for school bus identification, maintenance, and driver training. Each state determines how it will include Program Standard No. 17's guidelines in its highway safety program, and individual states have chosen to adopt some or all aspects of the standard. Florida state officials would be able to explain state implementation of Program Standard No. 17, if you are interested in further information.; Your first question asked whether we have any regulation that prohibit parents or booster club members from transporting children or students to school sponsored events in their own vehicles.; The answer to your question is no. As explained above, our requirement apply to the manufacture and sale of new motor vehicles. Manufacturers of new school buses certify their vehicles to our school bus safety standards and persons selling new school buses sell only complying school buses. NHTSA does not regulate users of motor vehicles, such as schools, parents, or any other vehicle owner, and we have no prohibition against vehicle owners using their own vehicles to transport school children to school-related events. However, states have authority to set requirements for vehicles used to transport school children. If Florida wishes to sanction use of only complying school buses to transport its school children, it may do so. Its recommendation that school boards not condone transporting school children in noncomplying vehicles is consistent with our belief that school buses certified to our school bus safety standards are the safest means of transportation for school children.; Your second question asked whether NHTSA has any regulation applicabl to state boards of education or booster club members when they purchase or lease a bus or multipurpose passenger vehicle for carrying school children to school-related events.; The answer to this question is no. As explained in our response to you first question, NHTSA's requirements apply to persons selling or leasing new school buses for school-related events, not to purchasers or users of school buses. However, I would like to emphasize that Federal law requires dealers who know that a new bus will be used to transport students to school-related events to sell complying school buses. The Safety Act's prohibition against selling new noncomplying vehicles or introducing them into interstate commence (sic) also requires dealers who *lease* new buses for school-related events to lease complying school buses.; Your next several questions concerned NHTSA's definitions fo 'passenger vehicles,' and 'conventional vans' of varying passenger capacities.; We assume that by 'passenger vehicle' you are referring to a 'passenge car.' NHTSA's definitions section of our motor vehicle safety standards, found at Title 49 of the Code of Federal Regulations (CFR) Part 571.3, defines a 'passenger car' as: 'a motor vehicle ... except a multipurpose passenger vehicle, designed for carrying 10 persons or less.'; You asked for our definition of a 'conventional van' and also asked ho we would classify a passenger van that carries 10 or fewer persons. Vans designed to transport passengers are classified by us as either multipurpose passenger vehicles (MPV's) or buses, depending on the number of persons they are designed to carry. A van which carries 10 or fewer persons and is constructed either on a truck chassis or with special features for occasional off- road operation is considered an MPV.; A 'bus' is defined by us as a motor vehicle designed for carrying mor than 10 persons. Thus, a van designed to carry more than 10 persons is considered a bus. New buses, including the 11 to 15 passenger vans you referred to, sold to carry school children must comply with our school bus safety standards.; Your final question concerned the applicability of our school bu regulations to privately-owned family vehicles used by parents to carry their children to or from school. NHTSA does not consider those vehicles subject to our school bus safety standards. The House Committee Report on the Vehicle Safety Act amendments directing NHTSA to issue school bus safety standards stated that '(p)rivate motor vehicles used to carry members of the owner's household or other students in a carpool arrangement' were among the types of motor vehicles not meant to come within the scope of the amendments. (House Report 93-1191, page 42.) Therefore, persons selling new buses or any other type of vehicle for family use would not be under an obligation to sell complying school buses.; I hope this information clarifies our requirements for school buses Congressman Bill Nelson's office contacted us by letter dated March 4, 1986, with respect to your inquiry. I will send the Congressman a copy of this response for his information.; Please contact my office if you have any further questions. Sincerely, Erika Z. Jones, Chief Counsel

ID: nht68-2.5

DATE: 05/14/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Northern California Ready Mixed Concrete and Materials Association

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 8, 1968, to Mr. George Nield, concerning the location requirements for clearance lamps as specified by Federal Motor Vehicle Safety Standard No. 108.

Enclosed is a copy of the Federal Motor Vehicle Safety Standards (with amendments and interpretations through February 15, 1968). Standard No. 108 appears on page 39 of this publication. The location requirements for clearance lamps are included in Table II (page 50), of the standard. Since the requirements specify locations as near as practicable to the upper left and right extreme edges of the vehicle, the exact locations will vary, depending upon the design and utilization of the vehicle on which the lamps are mounted. When the rear identification lamps are mounted at the extreme height of the vehicle, rear clearance lamps may be mounted at optional heights. I would also point out that Standard No. 108 is applicable to new vehicles manufactured for sale on or after the effective date of the standard.

With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approvals on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, the above comments are for your information only and in no way relieve the vehicle manufacturer

from his responsibility for certifying that the assembled vehicle meets the requirements of the standard.

Thank you for writing.

ID: nht78-2.28

DATE: 01/17/78

FROM: AUTHOR UNAVAILABLE; Joseph J. Levin, Jr.; NHTSA

TO: Hendrickson Mfg. Co.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your November 21, 1977, letter asking whether a school bus that is propelled by a propane-fueled engine is required to comply with Federal Motor Vehicle Safety Standard No. 301-75, Fuel System Integrity (49 CFR 571.301-75).

Paragraph S3 of Safety Standard No. 301-75 specifies that the standard applies to school buses that have gross vehicle weight ratings greater than 10,000 pounds and use fuel with a boiling point above 32 degrees F. Since the boiling point of propane is below 32 degrees F, Safety Standard No. 301-75 would not be applicable to a school bus propelled by a propane engine.

Please contact us if you have any further questions.

SINCERELY,

November 21, 1978

Chief Counsel National Highway Traffic Safety Administration

Ref: 571.301 Standard No. 301: Fuel system integrity

Dear Sir:

Hendrickson Manufacturing Company, as a manufacturer of custom school bus chassis over 10,000 GVWR pounds, requests a ruling that would determine if a school bus propelled by a propane fueled engine is required to comply with Standard 301, fuel system integrity.

HENDRICKSON MFG. CO.

Kenneth R. Brennan Engineer Mobile Equipment Division

CC: M. A. SIGNA; T. F. CRAMER; A. TABB

ID: aiam1799

Dear Mr. Multhaup: This responds to TRW's January 24, 1975, question whether S4.1(k) o Standard No. 209, *Seat belt assemblies*, requires separate labeling of both parts of a Type II seat belt assembly in those cases where webbing is used on both the 'tongue' and 'receptacle' sides of the assembly. You enclose a photograph of the seat belt assembly in question.; Section S3. defines 'Seat belt assembly' as 'any strap, webbing o similar device designed to secure a person in a motor vehicle in order to mitigate the results of any accident, including all necessary buckles and other fasteners...' The use of the word 'assembly' and the reference to 'buckles and other fasteners' makes clear that a seat belt assembly can be composed of more than one part.; Section S4.1(k) specifies that 'Each seat belt assembly' shall b permanently and legibly marked or labeled with certain information. This means that one label is required on each assembly, regardless of the number of components which constitute the assembly.; Therefore, so long as the two portions of a seat belt assembly are i fact designed for use in combination to secure a person in a motor vehicle in order to mitigate the results of any accident, one label satisfies the requirements of S4.1(k).; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: aiam5133

"Dear Mr. Cameron: This responds to your letter of November 23, 199 requesting information on 'the procedure to obtain certification for the repair and recertification of motor vehicle passenger restraints to comply with DOT 206-3206.' When you were contacted by Mary Versailles of my staff for clarification on what DOT 206-3206 is, you explained that you are also unfamiliar with this requirement but had been told that you had to comply with it. Based on your request, this letter will explain the laws and regulations administered by this agency, and the responsibilities of your company when you repair motor vehicle safety belts by replacing worn or frayed webbing. The National Highway Traffic Safety Administration (NHTSA) is authorized under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq., Safety Act) to issue motor vehicle safety standards that apply to the manufacture and sale of new motor vehicles and new items of motor vehicle equipment. NHTSA, however, does not approve motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. Instead, the Safety Act establishes a 'self-certification' process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. NHTSA has exercised its authority under the Safety Act to establish Standard No. 209, Seat belt Assemblies, (49 CFR 571.209) which sets forth strength, elongation, webbing width, durability, and other requirements for seat belt assemblies. This standard applies to all seat belt assemblies as separate items of motor vehicle equipment, regardless of whether the belts are installed as original equipment in a motor vehicle or sold as replacements. The Safety Act provides that no person shall manufacture, import, or sell any new item of motor vehicle equipment unless it complies with all applicable Federal motor vehicle safety standards. See 15 U.S.C. 1397(a)(1)(A). If you were manufacturing new seat belt assemblies to replace those with worn or frayed webbing, you would be required to certify that the new assemblies complied with Standard No. 209. If you were installing replacement assemblies, the manufacturer of those assemblies would have certified that the assemblies comply with Standard No. 209. The requirement that an item of motor vehicle equipment comply with all applicable safety standards applies only until the item's first purchase in good faith for purposes other than resale. See 15 U.S.C. 1397(b)(1). After such first purchase, the only provision in Federal law that affects modifications that can be made to the item is set forth in 15 U.S.C. 1397(a)(2)(A). That section provides that: No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard. This section would prohibit you from replacing the worn or frayed webbing in a manner that would negatively affect the seat belt assembly's compliance with Standard No. 209. Violations of this 'render inoperative' prohibition are subject to a civil penalty of up to $1,000 for each violation. We urge you to exercise care when repairing safety belts. The belts you repair will fail to achieve their intended purpose if the webbing breaks or separates from the hardware or vehicle in a crash. Additionally, you may wish to consult a private attorney familiar with the law regarding potential liability in tort for your business in these circumstances. I have enclosed an information sheet for new manufacturers of motor vehicle equipment that briefly explains the responsibilities imposed on manufacturers, and tells how to get copies of the relevant laws and regulations. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosure";